Internal reporting system policy

1. Commitment

Projectes Immobiliaris Costa Daurada, SLU (The Vila Home) wants anyone who becomes aware of an irregularity in the company to be able to report it safely. To that end, it has this internal reporting system, in accordance with Law 2/2023 of 20 February and with anti-money laundering legislation (Law 10/2010).

This channel is the preferred route for reporting irregularities, without prejudice to the reporting person’s ability to go to the authorities at any time.

2. Who can report

Anyone who has learnt of the facts in a work or professional context with the company: employees (including former employees and people who are not yet employees, such as job applicants), self-employed workers, shareholders, members of the management body, collaborators, interns, volunteers and people working for suppliers or contractors.

3. What can be reported

Acts or omissions that may constitute breaches of European Union law, criminal offences or serious or very serious administrative offences; and, in particular, breaches of the legislation on the prevention of money laundering and terrorist financing, or of the company’s internal policies on this matter.

You can also ask questions about the channel or about whether a particular conduct is permitted.

4. How to report

In writing, using the form on this channel (app.thevilahome.com/canal-denuncias), either anonymously or giving your own details; or at an in-person meeting, which is requested through the same form and held within a maximum of seven days.

Reports can also be made to the Autoridad Independiente de Protección del Informante (Independent Authority for Whistleblower Protection), to the Oficina Antifrau de Catalunya (Anti-Fraud Office of Catalonia) and, in matters of money laundering, to the Servicio Ejecutivo de la Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias (Sepblac, Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences).

5. Safeguards

Confidentiality: the identity of the reporting person and of the people mentioned is known only to whoever handles the report, and is not disclosed to the person concerned. It may only be provided to the judicial authority, the Ministerio Fiscal (Public Prosecutor’s Office) or the competent administrative authority in the context of an investigation.

Anonymity: anonymous reports are accepted and processed. The channel does not store the IP address or the browser of the person using it.

Prohibition of retaliation: any retaliation, threat or attempt against anyone who reports in good faith, and against those who help them, is prohibited.

Rights of the person concerned: presumption of innocence, right of defence, right to be heard and to know the facts attributed to them, at a time and in a manner that does not prejudice the investigation.

Data protection: data are processed in accordance with the channel’s privacy information.

6. System Manager

The management body has appointed a System Manager (Responsable del Sistema), who manages the channel independently, without receiving instructions and under a duty of secrecy.

If what you want to report concerns the person who manages the channel, you can go directly to the authorities listed in section 4. If it arrives through the channel, the System Manager abstains from taking part and the company entrusts its handling to an independent third party, with the same safeguards.

7. Review

This policy is approved by the management body and will be reviewed whenever the legislation or the company’s organisation changes.